D's Actual Taxable Estate | $1,300,000 | |
QDOT Property | 800,000 | |
Total | $2,100,000 | |
Gross Tax | | $829,800 |
Less: Unified Credit | | (192,800) |
Pre-2011 section 2056A estate tax | | $637,000 |
(A) State Death Tax Credit Computation: | | |
(1) State death tax paid by S's estate with respect to the QDOT [$40,000] plus state death tax previously paid by D's estate [$70,000] = $110,000. | | |
(2) Credit limit under section 2011(b) (based on D's adjusted taxable estate of $2,040,000 under sections 2056A(b)(2)(A) and 2011(b)) = $106,800. | | |
(B) State death tax credit allowable against section 2056A estate tax (lesser of paragraph (ii)(A)(1) or (2) of this Example 2 | | (106,800) |
Net Tax | | $530,200 |
Less: Tax that would have been imposed on D's taxable estate of $1,300,000 | | 225,400 |
Section 2056A Estate Tax | | $304,800 |